The EPA is considering the CBD Petition to ban lead ammo and fishing tackle, and is now accepting public comment.  Consider this your first, best, and potentially last opportunity to enter your opinion and feedback.  Go to the Regulations.Gov site to read the petition and enter your comments.


OK, seriously now…  I’ve been a little behind on some issues, especially since my personal laptop died on Sunday.  Fortunately, I’ve got a new source of hunting and outdoors news to keep track of the little things I’ve missed.  The new Camo Underground site is a repository of news articles, columns, and blogs about all things outdoors.  One of the things I’d have missed without this new site is the following:

On August 20, the NRA-ILA (National Rifle Association – Institute for Legislative Action) submitted a position document to the EPA (Environmental Protection Agency) in response to the CBD (Center for Biological Diversity) petition to ban pb (lead) in ammunition and fishing tackle.  I posted on the CBD petition a little while back, and it seems to have drawn little attention since then.  I guess the NRA and Co. have been getting their ducks in a row.

The letter is largely legalese, but in essence it challenges the CBD’s argument that the EPA should ban lead bullets and shot from ammunition.  The CBD uses the auspices of the Toxic Substances Control Act (TSCA) to suggest that the EPA must ban these components.  The NRA-ILA letter, on the other hand, points out that Congress excluded ammunition from the reach of the EPA, and that since bullets and shot are integral components of ammunition, the EPA would be overstepping its authority in banning them.  They appear to say, as I read it, that without the lead bullets or shot, ammunition wouldn’t be ammunition. 

I’m not so sure it’s a completely sound argument when I look at it from a layman’s perspective (I think there’s a hole in it… do you see it too?). 

 The whole thing takes place on a level of the legal playing field that I don’t think I’m qualified to play on, but I’d suggest that anyone interested read the letter before commenting.  If nothing else, I think it delineates the way the arguments are going to face off.  

You can read the whole thing here.

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